Cynthia A. Bell - Page 16

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             opposite is true.  Petitioner was prompted to pay her                    
             outstanding balance for each year when she learned that her              
             brokerage account was subject to backup withholding and a                
             school tax credit of $63 had been withheld.                              
                  Moreover, we find that the delay in payment of                      
             petitioner’s taxes and interest for 1998 and 1999 is                     
             attributable entirely to petitioner.  Certainly, petitioner              
             bears full responsibility for filing her returns for those               
             years and paying the taxes shown thereon on or about                     
             April 17, 2002, well past the filing and payment deadlines.              
             Petitioner also bears full responsibility for waiting until              
             March 29, 2004, to pay the outstanding liabilities owed for              
             both years.  We are not persuaded to hold otherwise based                
             upon her vague assertion that she thought “that all had                  
             been resolved”.  To do so would be to hold that petitioner               
             should be relieved of interest because of her confusion or               
             lack of full understanding of the balances due with respect              
             to her taxes for 1998 and 1999.  Accordingly, we find no                 
             basis on which to abate any interest assessed with respect               
             to petitioner’s 1998 and 1999 taxes.                                     
                  On the basis of the above,                                          

                                             An order and decision will               
                                        be entered for respondent.                    







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